RE: Vega pretrial prep

[Haytham Faraj <haytham@puckettfaraj.com>]

Do you have a standard discovery request?

I would ask for Kayla because she's an impeachment witness.  We know they're
calling Dana.

We should include in the discovery request a request for the names and
contact information of all government witnesses.

The request for the list of counselors should also include the contact
information of the counselors and discovery of all counseling records for
our client and Orcutt, counselors notes and appointment calenders.

-----Original Message-----
From: Boyer Capt John F [mailto:john.boyer@usmc.mil] 
Sent: Friday, October 15, 2010 11:58 AM
To: Haytham Faraj
Subject: RE: Vega pretrial prep

Sir,

I'm in the same spot, but am working on them today.

I have on my to-do list:

Discovery - highlighting
-Joint ethics reg
-Police reports for stolen gun
-All reports filed by Vega b/t Dec 2007-Jan 2009
-NCIC check of Dana Orcutt and Emilio (JR) Guerrero of San Jacinto, CA
-List of counselors working or who worked at MCRD Family Services in 2009 -
permanent, part time, temporary
-Record of counseling for Vega and Dana
-Verbatim transcript of Dana's testimony
-Verbatim transcript of MJO clerk's testimony (threat)
-Transcribed statement of Vega (NCIS interview) if the gov is going to offer
it
-Kayla Orcutt diary [Logan reported, she could not find it/it does not exist
- I will still request]
-If they produce Dana, we want Kayla to come (is this a witness request, or
something different?)

Motions:
-Motion in Limine to prohibit bringing up bubblegum incident
-Motion to suppress indecent language based on freedom of speech
-Motion to suppress uncorroborated statements (of Vega to NCIS), based on
MRE 304(g) - assuming Nuvia won't come in to testify

I have not heard about any good mil character or alibi witnesses from Vega.

If I've missed something or screwed something up, please let me know.

V/R,

John

-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
Sent: Friday, October 15, 2010 8:41
To: Boyer Capt John F
Subject: Vega pretrial prep

Hi John,

I've lost SA on some of our pretrial prep in Vega.  I think we owe a witness
request and a discovery request.  Did you send those out.  I don't recall
seeing either and have seen no response by the government.  Did SSgt Vega
discuss good character witnesses with us and possibly Albi witnesses?  I'm
available to discuss it today.

 

Haytham Faraj, Esq.

PUCKETT & FARAJ, PC

_______________________

WASHINGTON DC METRO

The Law Firm of Puckett & Faraj, PC

1800 Diagonal Road

Suite 210

Alexandria, VA 22314

703-706-0442 Phone

202-280-1039 Fax

 

DETROIT METRO

The Law Firm of Puckett & Faraj, PC

P.O. Box 1016

Dearborn Heights, MI 48127

313-457-1390 Phone

202-280-1039 Fax

 

 

www.puckettfaraj.com <http://www.puckettfaraj.com/> 

 

The information contained in this electronic message is confidential, and is
intended for the use of the individual or entity named above. If you are not
the intended recipient of this message, you are hereby notified that any
use, distribution, copying of disclosure of this communication is strictly
prohibited. If you received this communication in error, please notify
Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender.
You are required to purge this E-mail immediately without reading or making
any copy or distribution.